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Providing uniform consumer protection for distance education students located in all member states is a hallmark of the interstate reciprocity agreement known as the State Authorization Reciprocity Agreements (SARA). States that chose to join the agreement, often through state legislation signed by their governor, direct that the policies and procedures of the reciprocity agreement are to be followed for purposes of state institutional approval to offer distance education related activities to students located in states that are members to the reciprocity agreement.

As we reported in December, the National Council for State Authorization Reciprocity Agreements (NC-SARA) is facilitating the new SARA Policy Modification Process. This process began in January 2023 with proposal submissions. This newly approved process increases transparency and public engagement to address revisions and improvements to SARA Policy to manage reciprocity and consistent oversight of participating institutions serving students in 49 states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. During the January proposal submission window, more than sixty policy modification proposals were submitted from representatives of higher education regional compacts, postsecondary institutions, higher education organizations, and consumer advocates.

Why This is Important

  • State authorization requirements, if any, must be met by institutions in states where students are located when the institution offers interstate distance education.
  • Compliance with state requirements is required by federal regulation to participate in Title IV financial aid.
  • Reciprocity through SARA is accepted by federal regulation as an alternative to state-by-state approval.
  • SARA has been represented as being a “negotiated compromise” of state requirements in SARA Policy to provide uniform oversight of institutions and protections for students in SARA member states.  
  • SARA Policy is reviewed and revised through the SARA Policy Modification Process.
  • Policy proposals approved through this process could compel new compliance requirements for institutions to participate in SARA as well as provide new oversight responsibilities of SARA member states.

Short History of SARA Policy

The SARA Policy Manual was developed to implement the Unified State Authorization Reciprocity Agreement which was signed by all four regional compacts and NC-SARA. The policies and procedures found in the SARA Policy Manual provide the responsibilities of the institutions, states, regional compacts, and also NC-SARA as the entity facilitating collaboration of the regional compacts to implement SARA. Modifications to the policy have occurred since the origination of SARA as submitted to and approved by the NC-SARA Board of Directors. In June 2022, the NC-SARA Board approved the new SARA Policy Modification Process that was developed by representatives from each regional steering committee. This new process encourages opportunity for the public and state voices to improve upon SARA Policy to implement reciprocity and offer ability to enrich student consumer protections.

SARA Policy Modification Process Steps

The new SARA Policy Modification Process follows several designated steps. For 2023, we highlight several dates in the chart provided as we encourage you to participate in certain steps of the process by reviewing proposals, listening to the two public forums, and providing written comments during the 30-day comment period. From the NC-SARA Participate in SARA Policy Modifications webpage, you can access links to review the list of proposals, gain access to registration for public forums, and receive direction to submit written public comments.

Note that the final step in the annual proposal process is the release of the revised SARA Policy Manual at the end of the calendar year. My holiday wish is that the policy manual will be released in web form with a PDF-only version for download as an option.

2023 SARA Policy Modification Key Dates

January 3-February 3, 2023          Window to submit SARA Policy Modifications

March 1, 2023                                 SARA Policy Public Forum #1 (available to the public to hear proposals)

April 5, 2023                                     Deadline to amend or withdraw proposed SARA Policy modifications.

April 17 – May 17, 2023   Call for written public comments on proposed SARA Policy modifications

June 7, 2023       SARA Policy Public Forum #2 (available to the public to hear proposals)

July 5, 2023                                       Deadline to amend or withdraw proposed SARA Policy modifications

September 1, 2023                         Deadline for Regional Compacts to review and vote on proposals.

October 23-25, 2023                      NC-SARA Board vote on proposals approved by the regional compacts

December 31, 2023                        Revise SARA Policy Manual published on the NC-SARA website.

Summary of the 2023 Proposals

The central theme present in many of the submitted proposals for this 2023 policy modification proposal year is the enhanced oversight of institutions to provide increased student consumer protections. Protections should be found in clear policy language for institutions to comply in support of their students, strong state oversight of SARA participating institutions, and strong regional compact oversight of SARA member states. The proposals generally fell into several categories including:

  • Technical Corrections,
  • Definitions,
  • State Responsibilities, Oversight & Renewals,
  • Institution Eligibility, Oversight & Renewals,
  • Consumer Protection, and,
  • Coverage & Limitations of SARA (including Professional Licensure).

The largest number of proposals address the eligibility and responsibilities of the SARA participating institutions including the process and expectations for institutions when the state provides the annual participation renewal. Regional compacts and consumer advocates strongly recommend the importance of sufficient state enforcement capacity and more state specific oversight and authority by the state portal entity to hold the institutions accountable. Multiple proposals focus on the increased parameters if the state places an institution on provisional status. Additionally, several proposals suggest the need for transparency on the NC-SARA website to share the status of SARA participation, if the institution is placed on provisional status, as well as to provide student complaint data for each SARA participating institution.

Other proposals suggest revisions to professional licensure notification language and several, including one of our proposals, address removal/replacement of the C-RAC Guidelines. Additionally, we submitted a proposal to the Definition section to define “Explanatory Note,” in order to address the authority of advisory language that has not been vetted and approved through the SARA Policy Modification Process. Another of our proposals suggests increased regional compact oversight, including authority to place a state on monitored provisional status under certain circumstances when functional responsibilities are not met by a state. Conversely, another proposal suggested extending the regional compacts’ reviews of member states for membership renewal from biennially to every five years.

First SARA Policy Proposal Public Forum

Two weeks ago, approximately half of the proposals were presented by their submitters in a livestream public forum hosted by NC-SARA. Submitters were allotted three minutes to publicly share their proposed language and offer the rationale and importance of their proposal. Many submitters requested viewers reach out to them to offer suggestions for improvements for their proposed language. Submitters may amend their proposals and participate in a second public forum later in the spring.

While submitters of proposals offered the rationale for their language in the written proposal submission form during the initial proposal period, the verbal presentation, in many cases, offered the opportunity to share additional context and motivation for the proposed language. Additionally, some submitters provided support data and explained the interrelationship of multiple proposals on related policy.

The Next Steps in the Process and How to Participate

Consider providing a written comment during the public comment period April 17-May 17, 2023. In order to prepare a written comment, institutions and other interested parties should review the list of policy proposals to determine which proposals may be particularly applicable to your role in the SARA ecosystem. The list of proposals identifies the proposal name, affected SARA Policy sections, and the organization name. We think proposals of note to review include those:

  • addressing enforcement of state consumer protection laws,
  • ensuring states’ enforcement capacity,
  • related to C-RAC/21st Century Guidelines,
  • related to professional licensure, and,
  • multiple proposals addressing institutional provisional status.

Please consider these proposals and determine how each policy change could positively or negatively impact students or your role as associated with the implementation of the SARA agreement.

A second public forum will take place on June 7th following the public comment period. The submitters will have an opportunity to consider the written comments and revise their proposals in advance of the second public forum for which we encourage you to register and attend. During the public forum, many submitters are likely to express their interest in direct feedback from listeners offering you another opportunity to share questions, concerns, or support for the proposal(s) before the final deadline to amend proposals.


Your input is important to this process. The opportunity for increased participation was intentionally placed into the new modification process in order to hear voices of all stakeholders affected by SARA Policy.

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In regard to public comments, we would like to share some advice. Your constructive comments are essential! Submitters will appreciate comments in support as well as comments that address questions and concerns about their proposals. The comments will be available for public review on the NC-SARA website.

If you comment on behalf of your institution or organization, make sure you have the authority to do so. If you comment as an individual, you can’t use your institution or organization letterhead. You can supply your name, title, and employer as context as an indicator or your experience on the topic. Remember this is your importunity to provide input to SARA policy. If you have questions, concerns, or just need clarity, please raise them!  

SAN and WCET will continue to share more information as we watch and participate in this first year of the new SARA Policy Modification Process. Watch for us to share more soon!

Cheryl Dowd

Senior Director, State Authorization Network & WCET Policy Innovations

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